Recently promulgated final regulations govern partnership distributions of marketable securities

Article Abstract:

The final IRC 731(c) regulations on partnership distribution of marketable securities limit the amount of securities that can be recharacterized as cash. This change effectively ends a partner's ability to plan for and control gain recognition associated with distribution of a cash equivalent. The limits on the amount deemed distributed, return of prior contributions, exceptions to the deemed cash rule, technical terminations, investment partners' distributions, and partnership tiers are also covered by the regulations.

Partnerships, Laws, regulations and rules, Securities, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Securities taxes, Partnership distributions

---

Practical problems faced by pension plans holding partnership interests

Article Abstract:

Valuation and liquidity issues develop when pension plans have investments in real estate partnership interests. IRS Form 5500 guidelines for auditing pension plans' annual reports imply that contemporaneous valuations of partnership interests, rather than adjusted capital account or initial cost valuations, are the best means of supporting taxpayers' positions. The IRS allows the use of liquidation trusts when plans hold illiquid assets and employer sponsors have ceased business operations.

Real estate investment, Real estate investments, Valuation

---

Some points regarding pension plan ownership of real estate partnership interests

Article Abstract:

ERISA rules determine whether a qualified pension plan's ownership of real estate partnership interests should be characterized by the entity or flow-through approach. Plan investment due diligence requirements can become problematic, particularly if the interest ownership is characterized by the flow-through approach. Practitioners should also consider the Dept of Labor regulations and the Small Business Job Protection Act's effect on plan liquidity needs.

Pension Fund Investment Strategy, Partnership Interests, Management, Investments, Real estate, Real property, Investment plans

Similar abstracts:

• Abstracts: Poor relation. The attraction of opposites
• Abstracts: A heated interest in biomass power. Rage over right to roam
• Abstracts: New-build residential valuations. Seeing into the future. Lands of opportunity
• Abstracts: Single-tenant retail real estate valuation and financing: an enterprise approach. Opportunities abound in the hospitality industry
• Abstracts: A charitable undertaking. Insurers weather a changing market. Getting to grips with growth

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.